Def Jam founder Russell Simmons is asking a court to throw out a complaint filed by a woman identified as Jane Doe, who claims he raped her after a concert she attended in Sacramento with her elementary-school-age son.

Simmons calls the allegations “a work of pure fiction,” saying his accuser used “two of the most vile allegations possible” — threatening to molest her son before raping her — as a ploy to extract a large settlement.

In a response filed today in Los Angeles Superior Court, Simmons argues that the case should be dismissed because the alleged attack occurred on March 23, 1988 — well past the two-year statute of limitations for sexual assault or battery. The original complaint omitted the date.

“Plaintiff cannot assert claims for ‘forcible rape,’ intentional infliction of emotional distress or negligent infliction of emotional distress for an incident that purportedly took place 30 years ago,” Simmons’ attorneys argue in a response to the complaint.

 The woman claimed the music veteran invited her to an “after party” at his hotel, that they socialized together, and returned to Simmons hotel, where he allegedly delivered a chilling ultimatum: “I’m going to f__k you or I’m going to f__k your son. You decide.”

The woman’s suit seeks $10 million in damages.

Simmons’ attorney challenges the accuser’s credibility in a letter submitted as evidence in the music industry veteran’s response, noting that the original complaint leaves out “important facts” and makes illogical assertions.

“According to the complaint, Mr. Simmons made a threat of child abuse regarding (the) child when the child was not even present at the time. This makes no sense,” wrote attorney Jill Basinger. “Also, the complaint fails to acknowledge that (the woman) pled guilty to prostitution within two years of the alleged incident.”

Basinger noted that Jane Doe also filed for bankruptcy a few years ago.